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GRI STANDARD DISCLOSURE URL AND/OR PAGES NUMBER COMMENTS GRI General Disclosures GRI 102: General Disclosures 2016 102-1 Name of the organization Dell Technologies 102-2 Activities, brands, products, and services 10K – pages 5-7 102-3 Location of headquarters 10K – page 1 102-4 Location of operations 10K Manufacturing and Materials and Geographic Operations – page 8 Dell Locations 102-5 Ownership and legal form On December 18, 2018, Dell Technologies became a privately controlled public reporting company. Dell Technologies has privately held Class A and Class B Common Stock as well as publicly-traded Class C Common Stock. Stock Information Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – pages 73-78 10K Business – page 5 102-6 Markets served 10K Geographic Operations – page 8, Sales and Marketing – page 9 Our Brands Customer Stories 102-7 Scale of the organization 10K Selected Financial Data – pages 39-41, Employees – page 12 102-8 Information on employees and other workers 10K Employees – page 12 FY19 Corporate Social Responsibility (CSR) Report – By the Numbers, People – page 55 We provide data on total number of full-time employees and total percentage of female team members GRI Content Index This FY19 GRI index, references the GRI Standards 2016 disclosures, unless otherwise noted in the “Comments” section of this Index. This content index also supplements our FY19 Corporate Responsibility Report. GRI CONTENT INDEX / 1

GRI Content Index - Dell€¦ · reporting company. Dell Technologies has privately held Class A and Class B Common Stock as well as publicly-traded Class C Common Stock. Stock Information

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Page 1: GRI Content Index - Dell€¦ · reporting company. Dell Technologies has privately held Class A and Class B Common Stock as well as publicly-traded Class C Common Stock. Stock Information

GRI STANDARD DISCLOSURE URL AND/OR PAGES NUMBER COMMENTS

GRI General Disclosures

GRI 102: General Disclosures 2016

102-1 Name of the organization Dell Technologies

102-2 Activities, brands, products, and services

10K – pages 5-7

102-3 Location of headquarters 10K – page 1

102-4 Location of operations 10K Manufacturing and Materials and Geographic Operations – page 8Dell Locations

102-5 Ownership and legal form On December 18, 2018, Dell Technologies became a privately controlled public reporting company. Dell Technologies has privately held Class A and Class B Common Stock as well as publicly-traded Class C Common Stock.Stock InformationNotice and Proxy Statement for 2019 Annual Meeting of Stockholders – pages 73-7810K Business – page 5

102-6 Markets served 10K Geographic Operations – page 8, Sales and Marketing – page 9Our BrandsCustomer Stories

102-7 Scale of the organization 10K Selected Financial Data – pages 39-41, Employees – page 12

102-8 Information on employees and other workers

10K Employees – page 12FY19 Corporate Social Responsibility (CSR) Report – By the Numbers, People – page 55

We provide data on total number of full-time employees and total percentage of female team members

GRI Content IndexThis FY19 GRI index, references the GRI Standards 2016 disclosures, unless otherwise noted in the “Comments” section of this Index. This content index also supplements our FY19 Corporate Responsibility Report.

GRI CONTENT INDEX / 1

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GRI STANDARD DISCLOSURE URL AND/OR PAGES NUMBER COMMENTS

GRI General Disclosures (continued)

GRI 102: General Disclosures 2016(continued)

102-9 Supply Chain 2018 Supply Chain Sustainability (SCS) Progress Report – Letter from Kevin Brown, EVP, Global Operations and Chief Supply Chain Officer – page 2, Our Approach to Sustainability – page 310K – Manufacturing and Materials – page 8Sustainable Supply ChainOur SuppliersDell Supplier ListConflict Minerals Report

102-10 Significant changes to the organization and its supply chain

10K – Class V Transaction – page 12 Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – page 14There were no significant changes in our supply chain during FY19.

102-11 Precautionary principle or approach

Dell Policies & Positions:- Dell Global Environmental Policy- Dell’s Chemical Use Policy- Dell’s Guidelines for Management of Manufacturing Process Chemicals- Dell Producer Responsibility Policy- Dell Electronic Disposition PolicyAdvancing SustainabilitySustainable Products and ServicesCircularity at Work

102-12 External initiatives The Responsible Business Alliance (RBA)Responsible Minerals InitiativeThe Net Positive ProjectNext WaveReboot Representation Tech CoalitionEco labels

GRI CONTENT INDEX / 2

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GRI STANDARD DISCLOSURE URL AND/OR PAGES NUMBER COMMENTS

GRI General Disclosures (continued)

GRI 102: General Disclosures 2016(continued)

102-13 Membership of associations Membership and AssociationsCultivating Inclusion – Our Partnerships

102-14 Statement from senior decision maker

FY19 CSR Report – Letter from Michael Dell – page 3

102-15 Key impacts, risks, and opportunities

Dell’s Legacy of Good Plan10K – Government Regulation and Sustainability – pages 10-11, Risk Factors – pages 18-34FY19 CSR Report – 2020 Goals Dashboard – pages 7-21, Progress narrative by action area – pages 22-41, Support for SDGs – pages 42-43, Materiality & Our GRI Report –pages 44-46

102-16 Values, principles, standards, and norms of behavior

How We Win: Dell Technologies Code of ConductCode of ConductCorporate Governance PrinciplesFY19 CSR Report – Governance – pages 40-41

102-17 Mechanisms for advice and concerns about ethics

Code of Conduct – pages 54-58

102-18 Governance structure Board of Directors

Committee Composition

Governance Documents

102-19 Delegating authority Leadership Team

10K – Executive Officers of Dell Technologies – pages 14-17

102-20 Executive level responsibility for economic, environmental, and social topics

Ms. Karen H. Quintos, Chief Customer Officer of Dell Technologies, leads the Diversity and Inclusion and Corporate Responsibility business imperatives, which encompass social responsibility, entrepreneurship, and diversity.

GRI CONTENT INDEX / 3

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GRI General Disclosures (continued)

GRI 102: General Disclosures 2016(continued)

102-20 Executive level responsibility for economic, environmental, and social topics (continued)

Ms. Christine Fraser SVP and Chief Responsibility Officer, reporting to Ms. Quintos, leads Corporate Social Responsibility. Mr. Brian Reaves Chief Diversity and Inclusion Officer, also reporting to Ms. Quintos, leads Diversity and Inclusion.10K – Executive Officers of Dell Technologies – page 16FY19 CSR Report – Letter from Michael Dell – page 3, Letter from Christine Fraser & Brian Reaves – page 4Dell Technologies World – Social Impact at Dell Technologies

102-21 Consulting stakeholders on economic, environmental, and social topics

MaterialityReportingFY19 CSR Report – Materiality & Our GRI Report – page 44-46

102-22 Composition of the highest governance body and its committees

Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – pages 15-22Board of DirectorsCommittee Composition

102-23 Chair of the highest governance body

Code of Conduct – pages 54-58

102-25 Conflicts of interest Code of Conduct – page 47Code of Ethics for Senior Financial OfficersCorporate Governance Principles

102-26 Role of highest governance body in setting purpose, values, and strategy

Corporate Governance Principles - Ethics and Values – page 1Code of Conduct – pages 35, 59FY19 CSR Report – Governance – pages 40-41

102-27 Collective knowledge of highest governance body

Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – pages 17-22Corporate Governance Principles – pages 2-3Board of Directors

GRI CONTENT INDEX / 4

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GRI General Disclosures (continued)

GRI 102: General Disclosures 2016(continued)

102-30 Effectiveness of risk management processes

Corporate Governance Principles – Governance, compliance, and risk management –page 2Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – page 28As founding members of the RBA, we have fully adopted the RBA Code of Conduct for our own operations, and we expect our suppliers to abide by the Code and to expect the same of their suppliers. As part of this process and through the years we have implemented robust management systems—embedded in our operations—to identify, manage and mitigate risks in these areas (environmental, social and governance). In addition, our own facilities are subject to audits through RBA’s validated audit process. This audit process is one of the mechanisms we use to assess the effectiveness of our risk management processes for social, environmental and governance issues. During FY19, five of our facilities underwent RBAs audits. There were no priority findings. One of these facilities had one major nonconformance. Corrective action plans have been developed and are being implemented. We expect to have closure audits, as appropriate, during FY20.

102-31 Review of economic, environmental, and social topics

Annual review cycle.MaterialityFY19 CSR Report – Materiality & Our GRI Report – pages 44-46

102-32 Highest governance body’s role in sustainability reporting

The SVP and Chief Responsibility Officer is the primary executive responsible for approving the entire report. The Executive Leadership Team participates in the review and approval process. Other functional executives also review and approve relevant parts of the report such as operations, human resources, etc.FY19 CSR Report – Letter from Michael Dell – page 3FY19 CSR Report – Letter from Christine Fraser & Brian Reaves – page 4

102-33 Communicating critical concerns

There are different mechanisms available to raise concerns to the highest level of governance. These are described in our Corporate Governance Principles – page 7, our Code of Conduct – page 54 and the Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – Communications with Directors – page 29. To send an anonymous and confidential message for senior management or the board of directors, you can email any questions or comments to [email protected]

GRI CONTENT INDEX / 5

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GRI General Disclosures (continued)

GRI 102: General Disclosures 2016(continued)

102-34 Nature and total number of critical concerns

102-34b Code of Conduct – page 55Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – page 29

102-34a Confidentiality constraints. Dell treats this data as confidential company information.

102-35 Remuneration policies Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – Director Compensation pages 29-31; Executive Compensation – pages 51-71.

102-36 Process for determining remuneration

Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – Director Compensation – pages 29-31; Executive Compensation – pages 51-71.

102-37 Stakeholders’ involvement in remuneration

Corporate Governance Principles – page 7Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – Proposal 3 –Advisory vote to approve named executive compensation – page 34, Consideration on annual say-on-pay results – page 55.

102-38 Annual total compensation ratio

Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – Pay Ratio Disclosure – page 71.

102-39 Percentage increase in annual total compensation ratio

Notice and Proxy Statement for 2019 Annual Meeting of Stockholders – Pay Ratio Disclosure – page 71.

102-40 List of stakeholder groups MaterialityMembership and AssociationsCultivating Inclusion – Our PartnershipsCustomer Engagement Programs

102-41 Collective bargaining agreements

Human Rights and Labor Policy StatementRBA Code of Conduct – Freedom of Association – page 4

We do not use reference 102-41a. The percentage of employees covered by collective bargaining agreements is managed at a local level. We do not track or consider relevant the consolidated percentage.

GRI CONTENT INDEX / 6

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GRI General Disclosures (continued)

GRI 102: General Disclosures 2016(continued)

102-42 Identifying and selecting stakeholders

MaterialityFY19 CSR Report – Materiality & Our GRI Report – page 44-46

102-43 Approach to stakeholder engagement

MaterialityFY19 CSR Report – Materiality & Our GRI Report – page 44-46

102-44 Key topics and concerns raised

MaterialityFY19 CSR Report – Materiality & Our GRI Report – page 44-46Dell Technologies World - Social Impact as a Business Imperative with Dell Technologies Chief Customer Officer Karen Quintos

102-45 Entities included in the consolidated financial statements

10K – Business, page 5 – 7FY19 CSR Report About This Report – page 58

102-46 Defining report content and topic boundaries

FY19 CSR Report – Materiality & Our GRI Report – page 44-46, About This Report –page 58Materiality

102-47 List of material topics FY19 CSR Report – Materiality & Our GRI Report – page 44-46 Materiality

102-48 Restatements of information During FY19, we restated the following metrics:

2020 Goals Dashboard: • Sustainable Materials cumulative total: We are restating our cumulative total and

the amount of reclaimed carbon fiber for CY17 because we found an error in last year’s calculation.

By the Numbers: • Supplier diversity spend FY17 and FY18 due to changes in methodology.• CY16 and CY17 for all Supply Chain indicators due to changes in calculation

methodology. We now calculate these indicators on a calendar year basis rather than fiscal year basis. As such, these have been restated for comparability purposes.

GRI CONTENT INDEX / 7

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GRI General Disclosures (continued)

GRI 102: General Disclosures 2016(continued)

102-48 Restatements of information (continued)

• FY17 and FY18 Scope 3 GHG emissions –supply chain, due to improvements in calculation methodology.

• FY17 and FY18 People of Color team members due to an error. • FY18 Total number of ERG locations due to an error.

102-49 Changes in reporting During FY19 we had a few changes in our reporting: • We have added a new section to the “By the Numbers” for Sustainable Products

and Packaging. In this section, we now provide a breakdown of the different materials that contribute to the Sustainable Materials goal on an annual basis. In addition, we are now tracking and reporting our use of Ocean-bound plastic in packaging. We will continue tracking and reporting these metrics in this section moving forward. Please see FY19 CSR Report- By the Numbers – pages 53-54 for additional information.

• This year we are also closing our 2020 Plan, and launching our Progress Made Real: Our Vision for 2030.

102-50 Reporting period FY19 CSR Report – About This Report – page 58

102-51 Date of most recent report FY18 CSR Report

102-52 Reporting cycle Annual

102-53 Contact point for questions regarding the report

FY19 CSR Report– About This Report – page 58

102-54 Claims of reporting in accordance with the GRI Standards

FY19 GRI Content Index

102-55 GRI content index FY19 GRI Content Index

102-56 External assurance We conduct limited assurance of specific key performance indicators, including our GHG emissions and underlying energy consumption data, along with our water withdrawals and discharges and underlying data, is currently in progress. The FY19 assurance statement may be accessed here by July 29, 2019 (the FY18 statement will be at this link until then).

GRI CONTENT INDEX / 8

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Material Topics

Data Privacy and Security

103-1 Explanation of the material topics and its boundaries

FY19 CSR Report – Materiality & Our GRI Report – page 45, Governance Section –pages 40-41 10K – Risk Factors – page 23

GRI 103: ManagementApproach 2016

103-2 The management approach and its components

Privacy Statement Regarding Customer and Online User InformationDell Supply Chain Assurance

103-3 Evaluation of the management approach

FY19 CSR Report – Governance Section – pages 40-41

GRI 418 Customer Privacy 2016

418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data

Confidentiality constraints. Dell takes customer data and privacy very seriously and has strict standards and policies and robust management systems in place to prevent, mitigate and manage customers’ data and privacy.

Role of IT in Society

GRI 103:ManagementApproach 2016

103-1 Explanation of the material topics and its boundaries

FY19 CSR Report – Materiality & Our GRI Report – page 45, Progress narrative – Net Positive – pages 38-39 Transforming Lives with TechnologyNet Positive

103-2 The management approach and its components

Transforming Lives with TechnologyNet PositiveFY19 CSR Report – Progress narrative – Net Positive – pages 38-39

103-3 Evaluation of the management approach

FY19 CSR Report – 2020 Goals Dashboard – Net Positive – page 21, Progress narrative – Net Positive – pages 38-39

GRI CONTENT INDEX / 9

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Material Topics (continued)

Diversity and Inclusion

GRI 103: Management Approach 2016

103-1 Explanation of the material topics and its boundaries

FY19 CSR Report – Materiality & Our GRI Report – page 45Cultivating Inclusion

103-2 The management approach and its components

Cultivating InclusionDiversity and Equal Employment Opportunity PolicyCode of Conduct – pages 18-19Diversity and InclusionEthnic and Cultural EmpowermentGender EmpowermentTeam Member EmpowermentCommunity EmpowermentWorkforce of the FutureMitigating BiasSupplier Diversity

103-3 Evaluation of the management approach

FY19 CSR Report – 2020 Goals Dashboard – People – pages 18-20, Progress narrative – People – pages 34-37, By the Numbers – People – pages 55-562018 SCS Progress Report – Supplier Diversity –pages 27-29

GRI 405: Diversity and Equal Opportunity 2016

405-1 Diversity of governance bodies and employees

Board of DirectorsNotice and Proxy Statement for 2019 Annual Meeting of Stockholders – Directors –pages 18-22Our LeadershipFY19 CSR Report – By the Numbers – People – pages 55-56

We use 405-1a i and ii; and partially use 405-1b i and iii, as we do not provide breakdown by group age for team members.

405-2 Ratio of basic salary and remuneration of women to men

Confidentiality constraints Dell treats this data as confidential company information.

GRI CONTENT INDEX / 10

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Material Topics (continued)

Diversity and Inclusion (continued)

GRI 406: Non-discrimination 2016

406-1 Incidents of discrimination and corrective actions taken

Confidentiality constraints Dell treats this data as confidential company information.

STEM Education

GRI 103: Management Approach 2016

103-1 Explanation of the material topics and its boundaries

FY19 CSR Report – Materiality & Our GRI Report – page 45Youth LearningFY19 CSR Report – Communities – Youth Learning – pages 32-33

103-2 The management approach and its components

Youth LearningFY19 CSR Report – Communities – Youth Learning – pages 32-33

103-2 The management approach and its components

Youth LearningFY19 CSR Report – 2020 Goals Dashboard – Communities – page 17, Progress narrative – Communities – Youth Learning – pages 32-33, By the Numbers –Communities – page 55

Flexible Workforce

103-1 Explanation of the material topics and its boundaries

FY19 CSR Report – Materiality & Our GRI Report – page 45

GRI 103:ManagementApproach 2016

103-2 The management approach and its components

Work Flexibility at DellFY19 CSR Report – 2020 Plan Achievements – Flexible Work Options – page 6, 2020 Goals Dashboard – People – page 19

103-3 Evaluation of the management approach

FY19 CSR Report – 2020 Goals Dashboard – People – page 19, Progress narrative –page 36

GRI CONTENT INDEX / 11

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Material Topics (continued)

Energy and Emissions

GRI 103: Management Approach 2016

103-1 Explanation of the material topics and its boundaries

FY19 CSR Report – Materiality & Our GRI Report – page 45

103-2 The management approach and its components

Global Environmental PolicyGlobal Climate Policy PrinciplesClimate ChangeSustainable Supply Chain > EnvironmentSustainable OperationsSustainable Products and ServicesScience-based Emission Reduction targetsCDP – Climate ChangeEnergy Management System ISO 50001 – Dell (EMC) (Cork, Ireland)Energy Management System ISO 50001 – Dell Poland ManufacturingISO 14001 Environmental Management System – Worldwide CertificateThe FY19 assurance statement may be accessed here by July 29, 2019 (the FY18 statement will be at this link until then).

103-3 Evaluation of the management approach

FY19 CSR Report – 2020 Goals Dashboard – Environment – pages 7, 9-12, Progress narrative – pages 22, 25-27Energy Management System ISO 50001 – Dell (EMC) (Cork, Ireland)Energy Management System ISO 50001 – Dell Poland ManufacturingISO 14001 Environmental Management System – Worldwide CertificateThe FY19 assurance statement may be accessed here by July 29, 2019 (the FY18 statement will be at this link until then).Dell 2020 Energy Intensity Goal – Midterm Report

GRI CONTENT INDEX / 12

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Material Topics (continued)

Energy and Emissions (continued)

GRI 302: Energy 2016

302-1 Energy consumption within the organization

FY19 CSR Report – By the Numbers – Sustainable Operations – page 51 CDP – Climate Change

302-2 Energy consumption outside of the organization

No information available Dell Inc. does not track this indicator. However, we do track and report scope 3 emissions for relevant categories.

GRI 302: Energy 2016 (continued)

302-3 Energy intensity CDP – Climate Change

302-4 Reduction of energy consumption

CDP – Climate ChangeFY19 CSR Report – By the Numbers – Sustainable Operations – page 51

302-5 Reductions in energy requirements of products and services

FY19 CSR Report – 2020 Goals Dashboard – Environment – pages 11-12, Progress narrative page 25-27Sustainable Products and Services > Energy EfficiencyDell 2020 Energy Intensity Goal – Midterm Report

GRI 305: Emissions 2016

305-1 Direct (Scope 1) GHG emissions

CDP – Climate ChangeFY19 CSR Report – By the Numbers – Sustainable Operations – page 50

305-2 Energy indirect (Scope 2) GHG emissions

FY19 CSR Report – By the Numbers – Sustainable Operations – page 50CDP – Climate Change

305-3 Other indirect (Scope 3) GHG emissions

FY19 CSR Report – By the Numbers – Sustainable Operations – page 50CDP – Climate Change

305-4 GHG emissions intensity CDP – Climate Change

305-5 Reduction of GHG emissions FY19 CSR Report – 2020 Goals Dashboard – page 9, Progress narrative – page 25

305-6 Emissions of ozone-depleting substances (ODS)

No information available Dell does not produce, import or export ODS materials

GRI CONTENT INDEX / 13

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Material Topics (continued)

Energy and Emissions (continued)

GRI 305: Emissions 2016 (continued)

305-7 Nitrogen oxides (NOX), sulfur oxides (SOX), and other significant air emissions

No information available Dell has not estimated the emissions of these gases, but these are expected to be negligible.

Product Stewardship

GRI 103: Management Approach 2016

103-1 Explanation of the material topics and its boundaries

FY19 CSR Report – Materiality & Our GRI Report – page 45

103-2 Explanation of the material topics and its boundaries

Global Environmental PolicySustainable Products and ServicesDesign for Environment – white paperCircularity at WorkEco LabelsProduct Carbon FootprintsPosition Statement on REACHChemical Use PolicyProducer Responsibility PolicyElectronics Disposition PolicyDell RecyclingElectronics Disposition Partner Performance StandardThe Business Case for a Sustainable Supply ChainDell Waste Electrical and Electronic Equipment Disassembly InstructionsGlobal Takeback LeadershipISO 14001 Environmental Management System – Worldwide Certificate

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Material Topics (continued)

Product Stewardship (continued)

103-3 Evaluation of the management approach

FY19 CSR Report – 2020 Goals Dashboard – Environment – pages 11-15, Progress narrative pages 26-31ISO 14001 Environmental Management System – Worldwide CertificateDesign for Environment – white paperThe Business Case for a Sustainable Supply ChainHow to Recycle

GRI 301: Materials 2016

301-1 Materials used by weight or volume

Materials UseBio-based Resources

We do not currently track this KPI.

301-2 Recycled input materials used FY19 CSR Report – 2020 Goals Dashboard – Environment – pages 13-14, By the Numbers – Sustainable Product and Packaging – pages 53-54Recycled Materials

Because we do not currently track 301-1a, it is not possible to calculate 301-2a. Alternatively, we provide a cumulative total of sustainable materials used in products (2020 goals dashboard > product sustainable materials), and a breakdown of those by type of materials (By the Numbers). We do provide a percentage of sustainable and recyclable materials used in packaging, as percentage of total packaging used, by weight.

301-3 Reclaimed products and their packaging materials

FY19 CSR Report – 2020 Goals Dashboard – Environment – page 15. By the Numbers – Sustainable Operations – page 52

We do not use 301-3a and b. Alternatively, we provide the cumulative total amount of product takeback since FY08.

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Material Topics (continued)

Human Rights

GRI 103: Management Approach 2016

103-1 Explanation of the material topics and its boundaries

FY19 CSR Report – Materiality & Our GRI Report – page 45

103-2 The management approach and its components

How We Win: Dell Technologies Code of Conduct – page 20RBA Code of ConductDell Supplier PrinciplesHuman Rights and Labor Policy StatementStatement Against Slavery and Human TraffickingVulnerable Worker PolicyResponsible Minerals Policy2018 SCS Progress Report – Our Approach to Sustainability – pages 2-5Sustainable Supply Chain > Human Rights

103-3 Evaluation of the management approach

FY19 CSR Report – 2020 Goals Dashboard – Supply Chain – page 8, Progress narrative pages 22-23, By the Numbers – Supply Chain– pages 47-492018 SCS Progress Report – Letter to Our Stakeholders – page ii, Highlights – pages 8-12, Audit results – pages 33, 38-39

GRI 408: Child Labor 2016

408-1 Operations and suppliers at significant risk for incidents of child labor

2018 SCS Progress Report – 2018 RBA Audit Results – page 33, Labor and Human Rights audit results – page 38, Priority findings identified in 2018 – page 39Our aim is to audit 100% of our high-risk supplier facilities on a two-year cycle. During the FY18–FY19 cycle, 97% of our high-risk supplier facilities (including first-tier and sub-tier supplier facilities) underwent RBA third-party audits.

We present results on a consolidated basis as percentage of facilities in compliance with the RBA Code of Conduct.

GRI 409: Forced or Compulsory Labor 2016

409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labor

2018 SCS Progress Report - 2018 RBA Audit Results – page 33, Labor and Human Rights audit results – page 38, Priority findings identified in 2018 – page 39Statement Against Slavery and Human TraffickingOur aim is to audit 100% of our high-risk supplier facilities on a two-year cycle. During the FY18–FY19 cycle, 97% of our high-risk supplier facilities (including first-tier and sub-tier supplier facilities) underwent RBA third-party audits.

We present results on a consolidated basis as percentage of facilities in compliance with the RBA Code of Conduct.

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Material Topics (continued)

Human Rights (continued)

GRI 410: Security Practices 2016

410-1 Security personnel trained in human rights policies or procedures

No information availableCode of Conduct

Dell currently does not track this figure.

GRI 411: Right of Indigenous Peoples 2016

411-1 Incidents of violations involving rights of indigenous peoples

Dell is unaware of any part of our operations that would pertain to indigenous rights violations. Dell and Dell's suppliers are required to respect the human rights of others as detailed in our Code of Conduct, our Supplier Principles and the RBA Code of Conduct.

GRI 412: Human Rights Assessment 2016

412-1 Operations that have been subject to human rights reviews or impact assessments

Human Rights and Labor Policy Statement2018 SCS Progress Report – Building sustainable change through continuous improvement – page 3Our aim is to audit 100% of our high-risk supplier facilities on a two-year cycle. During the FY18–FY19 cycle, 97% of our high-risk supplier facilities (including first-tier and sub-tier supplier facilities) underwent RBA third-party audits.

412-2 Employee training on human rights policies or procedures

Code of Conduct – 100% of employees are required to take the Code of Conduct training and pass the associated test. The Code addresses core human rights aspects and risk areas.2018 SCS Progress Report – Sharing our knowledge to help suppliers reach long-term success – page 4

We do not track training using 412-2a, because Dell does not track training in terms of quantity of hours, but rather modules and courses completed.

412-3 Significant investment agreements and contracts that include human rights clauses or that underwent human rights screening

Dell Supplier PrinciplesSustainable Supply Chain2018 SCS Progress Report – Key Performance Indicators – page 31

Our aim is to audit 100% of our high-risk supplier facilities on a two-year cycle. During the FY18–FY19 cycle, 97% of our high-risk supplier facilities (including first-tier and sub-tier supplier facilities) underwent RBA third-party audits.

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GRI 200: Economic Topics

GRI 201: Economic Performance 2016

201-1 Direct economic value generated and distributed

10K – Selected Financial Data, pages 39-41

201-2 Financial implications and other risks and opportunities due to climate change

CDP – Climate Change10K – page 25Sustainable Operations > Climate Change

FY19 CDP Climate Change submission will be completed by July 31, 2019.

GRI 201: Economic Performance 2016

201-1 Direct economic value generated and distributed

10K – Selected Financial Data, pages 39-41

GRI 201: Economic Performance 2016 (continued)

201-3 Defined benefit plan obligations and other retirement plans

10K – pages 163-166

201-4 Financial assistance received from government

10K – pages 136-140

GRI 202: Market Presence 2016

202-1 Ratios of standard entry level wage by gender compared to local minimum wage

Confidentiality constraints Dell treats this data as confidential company information.

202-2 Proportion of senior management hired from the local community

No information available Dell does not disclose these percentages, however it is our common practice to promote and/or hire senior managers within the country/region that they manage.

GRI 203: Indirect Economic Impacts 2016

203-1 Infrastructure investments and services supported

FY19 CSR Report – Progress narrative – Communities – pages 32-33, By the Numbers – Communities – page 55Transforming Lives with Technology

203-2 Significant indirect economic impacts

FY19 CSR Report – Progress narrative – Communities – pages 32-33, By the Numbers – Communities – page 55Transforming Lives with Technology

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GRI 200: Economic Topics (continued)

GRI 204: ProcurementPractices 2016

204-1 Proportion of spending on local suppliers

Supplier Diversity OverviewFY19 CSR Report – By the Numbers –Supplier diversity spending – page 472018 SCS Progress Report – Supplier Diversity – pages 27-29

We report our spending with diverse suppliers, not as percentage of total procurement budget, but as an absolute figure.

GRI 205: Anti-Corruption 2016

205-1 Operations assessed for risks related to corruption

Dell analyzes for corruption risk within all global functions and departments annually.Code of Conduct – page 39FY19 CSR Report – Governance Section – pages 40-41

205-2 Communication and training about anti-corruption policies and procedures

All Dell employees receive Code of Conduct training annually. Code of Conduct – page 39FY19 CSR Report – Governance Section – pages 40-41Dell EMC Partner Code of Conduct – pages 4-5

205-3 Confirmed incidents of corruption and actions taken

Confidentiality constraints Dell treats this data as confidential company information.

GRI 206: Anti-Competitive Behavior 2016

206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

Code of Conduct – page 14Zero legal actions.

GRI 300: Environmental Topics

GRI 301: Materials 2016

See Material Topics section above

GRI 302: Energy 2016

See Material Topics section above

GRI 303: Water 2016 303-1 Water withdrawal by source FY19 CSR Report – By the Numbers – Sustainable Operations – pages 51-52CDP – WaterDell Water Policy PrinciplesSustainable Operations > Water and Waste

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GRI 300: Environmental Topics (continued)

GRI 303: Water 2016 (continued)

303-2 Water sources significantly affected by withdrawal of water

No information available. Dell does not directly withdraw significant quantities of water from any source. Municipal supplies of water are, to the best of our knowledge, not sensitive or Ramsar-listed. Our CDP – Water Disclosure for FY18 question W1.2 listed several countries or cities where water supplies are stressed, following the Aqueduct modeling. We do not report on the specific sources

303-3 Water recycled and reused CDP – Water

GRI 304: Biodiversity 2016

304-1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas

No information available Dell is unaware of any significant impacts on biodiversity in protected areas resulting directly from its activities.

304-2 Significant impacts of activities, products, and services on biodiversity

No information available Dell is unaware of any significant impacts on biodiversity resulting from its activities.

304-3 Habitats protected or restored Plant a Tree Program

304-4 IUCN Red List species and national conservation list species with habitats in areas affected by operations

No information available Dell's operations do not have a known impact on any endangered species.

GRI 306: Effluents and Waste 2016

See Material Topics section above

GRI 306: Effluents and Waste 2016

306-1 Water discharge by quality and destination

CDP – Water Our wastewater discharges consist primarily of domestic sewage released to wastewater public utilities. Additional details will be available in our 2019 CDP Water Disclosure.

We do not use 306-1a ii, iii.

306-2 Waste by type and disposal method

FY19 CSR Report – By the Numbers – Sustainable Operations – pages 52-53

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GRI 300: Environmental Topics (continued)

GRI 306: Effluents and Waste 2016 (continued)

306-3 Significant spills Dell did not have any significant spills during FY19 .

306-4 Transport of hazardous waste No information available Dell's operations generate only small amounts of hazardous wastes (all facilities are conditionally exempt from small quantity generators, or equivalent), typically from maintenance of facility equipment such as heating/cooling systems. Wastes are managed according to local regulatory requirements and are recycled where feasible. Hazardous wastes are not exported. The total amount is not fully tracked at the corporate level.

306-5 Water bodies affected by water discharges and/or runoff

No information available We do not track this information

GRI 307: Environmental Compliance 2016

307-1 Non-compliance with environmental laws and regulations

Dell was not assessed for any material environmental fines nor did we have any material environmental remediation or other environmental costs during FY19.

GRI 308: Supplier Environmental Assessment 2016

308-1 New suppliers that were screened using environmental criteria

2018 SCS Progress Report – Key Performance Indicators – page 31

308-2 Negative environmental impacts in the supply chain and actions taken

2018 SCS Progress Report – Mitigating environmental risks – page 26

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GRI 400: Social Topics

GRI 401: Employment 2016

401-1 New employee hires and employee turnover

CareersFY19 CSR Report – People – Pages 34-37

Dell considers this information proprietary and therefore does not publicly disclose it.

401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees

Our Benefits

401-3 Parental leave No information available

GRI 402: Labor/Management Relations 2016

402-1 Minimum notice periods regarding operational changes

Confidentiality ConstraintsCode of ConductRBA Code of Conduct

Dell treats this data as confidential company information.

GRI 403: Occupational Health and Safety 2016

403-1 Workers representation in formal joint management–worker health and safety committees

Global Health and Safety PolicyOHSAS 18001 Certificate

We do not track this metric. We provide a link to our Global Health and Safety Policy and to the Worldwide, Multi-site OHSAS 18001 Certificate.

403-2 Types of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities

FY19 CSR Report – By the Numbers – People – page 56

403-3 Workers with high incidence or high risk of diseases related to their occupation

Health and safety programs designed to prevent workplace injuries and illnesses are in place for employees throughout the company. Dell's very low occupational injury and illness incident rate demonstrates the effectiveness of these programs.

403-4 Health and safety topics covered in formal agreements with trade unions

Confidentiality constraints Dell treats this data as confidential company information.

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GRI 400: Social Topics (continued)

GRI 404: Training and Education 2016

404-1 Average hours of training per year per employee

No information available Dell does not track training in terms of quantity of hours, but rather modules and courses completed.

404-2 Programs for upgrading employee skills and transition assistance programs

Growing Your Career

404-3 Percentage of employees receiving regular performance and career development reviews

Dell’s performance management system links individual goals with organizational performance. The performance management process requires annual formal reviews, the calibration of talent and allocation of performance rewards and promotions — all decisions in line with being a meritocracy. Throughout the year, managers provide employees with ongoing feedback, coaching, training and on-the-job development. Employees and managers mutually create the employee-development plans. This entire process aligns individual-performance objectives and career-development planning with business and company goals and results.

GRI 405: Diversity and Inclusion 2016

See Material Topics section above

GRI 406: Non-discrimination 2016

See Material Topics section above

GRI 407: Freedom of Association and Collective Bargaining 2016

407-1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk

Human Rights and Labor Policy Statement

Code of Conduct

RBA Code of Conduct

2018 SCS Progress Report – page 5

GRI 408: Child Labor 2016

See Material Topics section above

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GRI 400: Social Topics (continued)

GRI 409: Forced or Compulsory Labor 2016

See Material Topics section above

GRI 410: Security Practices 2016

See Material Topics section above

GRI 411: Rights of Indigenous People 2016

See Material Topics section above

GRI 412: Human Rights Assessment 2016

See Material Topics section above

GRI 413: Local Communities 2016

413-1 Operations with local community engagement, impact assessments, and development programs

FY19 CSR Report – Communities Progress narrative – pages 32-33, By the Numbers – Communities – page 55Transforming Lives with Technology

413-2 Operations with significant actual and potential negative impacts on local communities

No information available Not applicable

GRI 414: Supplier Social Assessment 2016

414-1 New suppliers that were screened using social criteria

2018 SCS Progress Report – Key Performance Indicators – page 31

414-2 Negative social impacts in the supply chain and actions taken

2018 SCS Progress Report – Supply Chain Sustainability Highlights – pages 7-19

GRI 415: Public Policy 2016

415-1 Political contributions Public Policy

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GRI 400: Social Topics (continued)

GRI 416: Customer Health and Safety 2016

416-1 Assessment of the health and safety impacts of product and service categories

Dell Inc. (Dell) is committed to compliance with the laws and regulations in each country into which the company ships our products. All Dell products are designed and tested to meet the appropriate worldwide standards for Product Safety, Electromagnetic Compatibility, Ergonomics and other regulatory compulsory requirements, when used for their intended purpose.

416-2 Incidents of non-compliance concerning the health and safety impacts of products and services

All reports of possible safety issues are investigated. Dell Inc. is not aware of any incidents traced to a product non-compliance for FY19.

GRI 417: Marketing and Labeling 2016

417-1 Requirements for product and service information and labeling

ISO CertificationsChemical Use PolicyDell Eco-labelsResponsible SourcingProduct Carbon FootprintsRBA Code of ConductProduct Safety, EMC and Environmental Datasheets

417-1b. We do not track this indicator.

417-2 Incidents of non-compliance concerning product and service information and labeling

Confidentiality constraints Dell treats this data as confidential company information.

417-3 Incidents of non-compliance concerning marketing communications

Confidentiality constraints Dell treats this data as confidential company information.

GRI 418: Customer Privacy 2016

See Material Topics section above

GRI 419: Socioeconomic Compliance 2016

419-1 Non-compliance with laws and regulations in the social and economic area

Confidentiality constraints Dell treats this data as confidential company information.

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